The LCF Group, Inc. v. Columbia Steel, Inc., 2:23-cv-07983

The LCF Group, Inc. sued Columbia Steel, Inc. and related entities in New York state court for breach of contract.
Defendants removed the case to the U.S. District Court for the Eastern District of New York.
Plaintiff filed a motion to remand the case back to state court and requested attorneys’ fees.
The District Judge referred the remand motion to Magistrate Judge Tiscione for a Report and Recommendation (R&R).
Judge Tiscione recommended remanding the case to state court but denying plaintiff's request for attorneys’ fees.
No party objected to the R&R, and the District Judge adopted it in full after independent review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Remand to state court	Removal was improper; wants remand	No meritorious opposition on record	Remand granted
Attorneys’ fees upon remand	Entitled to fees under 28 U.S.C. § 1447(c)	No opposition on record	Attorneys’ fees denied

Grassia v. Scully, 892 F.2d 16 (2d Cir. 1989) (stating standard for district court review of a magistrate judge's report and recommendation)
Smith v. Campbell, 782 F.3d 93 (2d Cir. 2015) (failure to object to R&R waives judicial review)
Mario v. P & C Food Mkts., Inc., 313 F.3d 758 (2d Cir. 2002) (same)
United States v. Snow, 462 F.3d 55 (2d Cir. 2006) (standard for clear error review)
United States v. Garcia, 413 F.3d 201 (2d Cir. 2005) (defining clear error)